Germany–Switzerland · Moving to Germany
Acquisition Costs · Vorabpauschale · InvStGSwiss Funds and ETFs After Moving to Germany
If you move from Switzerland to Germany and continue to hold funds or ETFs, German investment tax rules apply once your German tax liability begins. A particularly important point: moving to Germany does not automatically revalue privately held fund units to their market value on the date of arrival. Historical acquisition costs, fund classification, Vorabpauschalen and data relating to older holdings should therefore be documented early.
Starting Point
Your existing Swiss fund portfolio becomes relevant for German tax after your move
Once you become subject to unlimited German tax liability, investment income from funds and ETFs held in a Swiss securities account generally also becomes relevant for German tax purposes.
The location of the custodian bank must be distinguished from the fund’s domicile. An ETF held at a Swiss bank may, for example, be domiciled in Ireland, Luxembourg or the United States.
For German tax purposes, the investment must be classified independently under the German Investment Tax Act (InvStG).
Moving to Germany ≠ A New Acquisition
German taxation begins, but the investment itself is not purchased again
Merely changing your tax residence from Switzerland to Germany does not constitute an actual acquisition of the fund units you already hold.
Historical acquisition and tax data must therefore continue to be maintained.
- German tax liability begins
- The fund remains the same
- The acquisition date remains relevant
- Historical acquisition costs remain important
- No general step-up to market value
- A subsequent sale is subject to German InvStG rules
Acquisition Costs
The market value on the date of arrival does not automatically become your new acquisition cost
For a subsequent sale of privately held fund units, section 19 InvStG refers to the gain calculation under section 20(4) of the German Income Tax Act (EStG).
The starting point is therefore generally the actual acquisition costs for tax purposes. The German Investment Tax Act contains no general provision treating existing fund units as newly acquired at their current market value merely because the investor moves to Germany.
ETF purchased for EUR 60,000 and worth EUR 100,000 on arrival
An individual purchases an ETF while resident in Switzerland for the equivalent of EUR 60,000.
When the individual later moves to Germany, the ETF has a market value of EUR 100,000.
The move does not, in itself, automatically establish EUR 100,000 as the new acquisition cost for German tax purposes. The historical acquisition details must therefore be preserved.
You should still document the market value on the date of arrival
Although it does not automatically replace the acquisition cost for German tax purposes, the value on arrival is important for cross-border documentation. In particular, it can help distinguish changes in value before and after the move and analyse special cases or tax treaty issues.
Once German Tax Liability Begins
Review distributions, Vorabpauschalen and subsequent disposal gains separately
Section 16 InvStG identifies three principal categories of investment income.
Distributions
Fund distributions received after German tax liability begins must be assessed under German investment tax rules.
Vorabpauschale
Accumulating funds or funds with low distributions may give rise to a German advance lump-sum investment income amount (Vorabpauschale).
Disposal
On a subsequent sale, the gain is calculated under German investment tax rules.
Swiss fund taxation and the German InvStG are different systems
Swiss taxable income, Swiss tax values or a Swiss bank report do not automatically determine the German tax base.
Year of Arrival
The statutory date of deemed receipt is decisive for the Vorabpauschale
Under section 18(3) InvStG, the Vorabpauschale is deemed to be received on the first working day of the following calendar year.
For example, if an individual moves to Germany during 2026 and is tax resident in Germany on the first working day of 2027, the Vorabpauschale for the 2026 calendar year may therefore become relevant.
Moving to Germany is not the same as acquiring the fund units
Section 18(2) InvStG expressly provides for a pro rata reduction in the year of acquisition. If the fund units have already been held for several years, a subsequent move to Germany does not automatically make them units acquired in the year of arrival.
The ETF was purchased in Switzerland in 2023
The investor moves to Germany on 1 July 2026. They have held the ETF since 2023.
The Vorabpauschale for 2026 is not deemed to be received until the first working day of 2027. The statutory reduction for the year of acquisition does not apply merely because of the move, as the ETF was not acquired in 2026.
The actual calculation therefore requires a review of the annual values prescribed by law, distributions and the base interest rate applicable for 2026.
The base interest rate for 2026 is 3.20%
Under section 18 InvStG, the base return is calculated using 70% of the base interest rate. For 2026, this corresponds to a calculation factor of 2.24% before further limitations are applied.
Selling After the Move
A subsequent sale is not simply taxed on the increase in value since arrival
For privately held investment fund units, disposal gains are calculated under section 19 InvStG in conjunction with section 20(4) EStG.
German rules generally do not provide for a general step-up to market value on the date of arrival merely because an investor moves to Germany.
This makes your Swiss purchase history essential
Investors who acquired funds many years before moving should make sure they preserve the original acquisition records.
Without reliable historical records, calculating the subsequent gain for German tax purposes can become considerably more difficult.
- Original purchase date
- Original acquisition costs
- Foreign currency data
- Corporate actions
- 2017/2018 values for older holdings
- German Vorabpauschalen after the move
- Partial exemption on sale
Swiss Francs
Historical acquisition costs in CHF must be determined in euros for German tax purposes
For transactions conducted in a currency other than the euro, section 20(4) EStG requires proceeds to be converted into euros at the time of disposal and acquisition costs at the time of acquisition.
As a result, the German taxable gain may differ from the gain in CHF shown in the Swiss securities account report.
Purchase
Record historical acquisition costs at the euro value relevant to the German calculation.
Currency effects
Changes in the CHF/EUR exchange rate can affect the disposal gain for German tax purposes.
Sale
Determine the sale proceeds in euros at the relevant point in time.
Fund Classification
After the move, the fund type must be determined under German investment tax law
A Swiss fund classification does not replace an assessment under the German InvStG.
| Fund type | Partial exemption for private holdings | Taxable portion |
|---|---|---|
| Equity fund | 30% | 70% |
| Mixed fund | 15% | 85% |
| Real estate fund | 60% | 40% |
| Foreign real estate fund | 80% | 20% |
| Other investment fund | Generally 0% | 100% |
The partial exemption applies to several types of income
Depending on the fund’s classification, it may apply in particular to distributions, Vorabpauschalen and disposal gains.
Older Holdings
Long-held funds also require a review of the 2018 investment tax reform
Fund units acquired before 1 January 2018 are subject to the transitional rules in section 56 InvStG.
Older units are generally deemed to have been sold at the end of 31 December 2017 and reacquired at the beginning of 1 January 2018.
Original purchase
Continue to preserve the acquisition date and original purchase documents.
Transitional value
Document the redemption price or market value at the end of 2017.
New InvStG regime
The reformed German Investment Tax Act applies from 2018 onwards.
Moving to Germany does not erase the history of the 2018 transition
If a fund was held long before the move, the statutory transitional values may need to be reconstructed for German taxation of a subsequent sale.
Funds Acquired Before 2009
Grandfathered fund units require a separate review
Section 56(6) InvStG contains special transitional rules for certain investment fund units acquired before 1 January 2009.
The original purchase date alone should not be used to conclude that a subsequent sale will be exempt from German tax. The statutory 2017/2018 rules and the special allowance for grandfathered fund units are particularly relevant.
EUR 100,000 allowance
For certain grandfathered fund units, section 56(6) InvStG provides a personal allowance of EUR 100,000 for relevant changes in value from 2018 onwards.
Keeping Your Funds in Switzerland
Transferring the securities account to Germany is not required for German taxation
After moving to Germany, you can generally continue to hold your fund portfolio at a Swiss bank.
For tax purposes, however, this often creates additional preparation work because the Swiss institution generally does not withhold German investment income tax or calculate all values required under German investment tax law.
Distributions
Record them separately for German tax purposes.
Vorabpauschale
With a Swiss securities account, you generally need to arrange the calculation yourself.
Partial exemption
Classify the fund under the German InvStG.
Sale
Calculate the German taxable gain independently of the Swiss bank report.
Alternatively, the securities account can be transferred to Germany later
If you do so, preserve the complete tax history, including acquisition costs, data relating to older holdings and Vorabpauschalen.
German Tax Return
You must declare investment income that has not been subject to German withholding tax
If funds or ETFs remain with a Swiss custodian bank, their income is generally not subject to German investment income tax withholding.
The relevant investment income must therefore be calculated and reported in your German income tax return.
| Situation | Typical German tax issue to review |
|---|---|
| Distribution after moving to Germany | Investment income and partial exemption |
| Accumulating fund | Vorabpauschale |
| Sale | Gain under section 19 InvStG |
| Swiss withholding tax | Check eligibility for a tax credit or refund |
| Foreign currency | Determine euro values for German tax purposes |
Before and After the Move
Eight steps for existing fund holdings in Switzerland
Record your holdings
Document all funds, ISINs and unit quantities at the time of your move.
Preserve purchase history
Archive original acquisition data and purchase documents.
Record arrival values
Document the market value of each position on the date of arrival.
Review older holdings
Identify acquisitions before 2018 or before 2009.
Classify the funds
Determine whether each holding is an equity fund, mixed fund, real estate fund or other fund.
Review the year of arrival
Determine the relevant timing of distributions and any Vorabpauschale.
Start German tax records
Document German Vorabpauschalen annually for each position.
Choose your account strategy
Continue using the Swiss securities account or consider a transfer to Germany.
Common Mistakes
Common errors when handling Swiss fund holdings after moving to Germany
Assuming an automatic step-up
The market value on arrival is used as the new acquisition cost without checking the legal basis.
Losing purchase documents
Swiss acquisition records are not permanently preserved after the move.
Overlooking the Vorabpauschale
Accumulating funds are treated as irrelevant for tax because they make no distributions.
Treating arrival as an acquisition
The acquisition-year reduction under section 18(2) InvStG is applied solely because the investor moved to Germany.
Copying the Swiss report
Swiss tax values are used unchanged for German tax purposes.
Using the gain in CHF
No separate calculation of the German taxable gain in euros is performed.
Forgetting the 2018 transition
Long-held funds are reviewed without considering section 56 InvStG.
Assuming every ETF is an equity fund
The partial exemption is applied without checking the fund’s classification.
Frequently Asked Questions
Swiss funds and ETFs after moving to Germany
Is my Swiss fund portfolio subject to German tax after I move to Germany?
Are my funds automatically stepped up to their current market value when I move?
Should I still document the market value on the date of arrival?
Which acquisition cost records do I need?
Can a Vorabpauschale arise for the year in which I move?
Is the Vorabpauschale reduced pro rata because I moved during the year?
What happens to gains that accrued while I was still in Switzerland?
Do I have to transfer my Swiss securities account to Germany?
Will my Swiss bank calculate my German Vorabpauschale?
Does the partial exemption also apply to my Swiss funds?
What rules apply to funds I purchased before 2018?
What rules apply to funds I purchased before 2009?
Can I use the Swiss tax report for my German tax return?
Further Tax Knowledge
Funds and ETFs after moving to Germany
Germany–Switzerland Tax Advice
Moving from Switzerland to Germany while holding funds or ETFs?
We review historical acquisition costs, fund classification, partial exemptions, the Vorabpauschale for the year of arrival, older holdings, Swiss securities account records and German taxation of a subsequent sale.
Request a Fund Review Before Your Move